https://www.taxtmi.com/highlights?id=96130 Capital gains arising on sale of shares held by Mauritius-incorporated companies are taxable in India where residence and treaty relief are contestable and transactions lack commercial substance; the article finds documentary timelines, post hoc board approvals, contra-factual tax positions and a shifted evidentiary burden establish a prima facie tax-avoidance scheme enabling anti-avoidance doctrines (including GAAR and substance-over-form) to pierce the structure, with applications for advance rulings rejected under the relevant proviso and Chapter X-A applying to transfers on or after 01.04.2017. en-us Sat, 17 Jan 2026 12:06:50 +0530 Sat, 17 Jan 2026 12:06:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=96130 Capital gains arising on sale of shares held by Mauritius-incorporated companies are taxable in India where residence and treaty relief are contestable and transactions lack commercial substance; the article finds documentary timelines, post hoc board approvals, contra-factual tax positions and a shifted evidentiary burden establish a prima facie tax-avoidance scheme enabling anti-avoidance doctrines (including GAAR and substance-over-form) to pierce the structure, with applications for advance rulings rejected under the relevant proviso and Chapter X-A applying to transfers on or after 01.04.2017. Highlights Income Tax Sat, 17 Jan 2026 12:06:50 +0530 https://www.taxtmi.com/highlights?id=96130